By
Bakampa Brian Baryaguma
1.
Introduction
The
extreme terror and horrors of the world wars (I and II) of the twentieth
century, followed by the arms race mainly between Russia and United States of America,
originating from the Russians’ explosion of an atomic bomb on 29 August, 1949,[1]
which proved so contagious, affecting all parts of the earth and subsequently
leading to the Cold War, again between Russia and United States of America, in
which the two super powers sponsored brutal civil wars around the world, were
eye openers to mankind, of the need for state and individual restraint for the
sake of peace and security. The world wars were so ferociously and zealously
fought,[2]
that World War I (1914-1918) alone claimed 13 million people, 10.5 million of
whom were from Eastern Europe![3]
Thereafter, World War II (1939-1945) broke out in Europe, ushering in a new
phase of global warfare in which, ‘War ... became well and truly industrialized
as industry became no less well and truly militarized,’[4]
leading to so much widespread carnage that human life was de-sanctified and
rendered worthless. The scale and intensity of these wars transmogrified human
beings into bloodthirsty and tyrannous creatures.
Consequently,
the elimination of international anarchy and disorder has ranked highly on the
international agenda ever since. The brutality exhibited in the 20th
century aroused heightened awareness and consciousness of the need for
international peace and security. Today, the world aspires to the following:
first, ‘... to save succeeding generations from the scourge of war, which twice
in our lifetime has brought untold sorrow to mankind;’ and second, ‘to unite
our strength to maintain international peace and security, and to ensure, by
the acceptance of principles and the institution of methods, that armed force
shall not be used, save in the common interest ....’[5]
To
achieve these objectives, there has been a heightened nurturing of
international law on use of force in resolving international conflicts. This
essay studies this law, its effectiveness in guaranteeing international peace
and security in the 21st century and analyzes the areas to be
strengthened.
2.
The
International Law on Use of Force and its Effectiveness in Guaranteeing
International Peace and Security
The
main sources of the international law on use of force are the Charter of the
United Nations (hereinafter ‘the UN Charter’), UN General Assembly Resolutions
and international customary law.
A.
The UN Charter
The
starting point is Article 2(4) of the UN Charter, which obliges all states to
‘... refrain in their international relations from the threat or use of force
against the territorial integrity or political independence of any state ....’ This
article states the general rule of contemporary international law on use of
force; that states are obliged to avoid using force in conducting their
international relations. This obligation is considered a rule of jus cogens,[6]
meaning compelling law i.e. ‘... a norm thought to be so fundamental that it
invalidates rules consented to by states in treaties or custom.’[7]
Therefore, as a general rule of the international law on use of force, states
cannot agree to conduct their international relations in a manner that accepts
or validates resort to use of force.
However,
there are two recognized and established exceptions to the general rule in Article
2(4) of the UN Charter namely, the right of self-defence and UN authorisation.
The first exception – the right of self-defence – is contained in Article 51 of
the UN Charter, while the second exception – UN authorisation – is deciphered from
the general scheme of the UN Charter.
1.
The
Right of Self-Defence
Article
51 of the UN Charter permits the use of force in self-defence. It provides that
nothing in the Charter impairs the inherent right of individual or collective
self-defence if an armed attack occurs against a UN member, until necessary measures
have been taken by the Security Council to maintain international peace and
security. Any measures taken in self-defence should be immediately reported to
the Security Council, which has absolute authority and responsibility under the
Charter, to take such action it deems necessary in order to maintain or restore
international peace and security.
Therefore,
as long as there is an armed attack occurring against a UN member state, the
use of force in self-defence is lawful, until the Security Council decides or directs
otherwise. There are three important criteria to be noted here that must be
satisfied: the occurrence of an armed attack; against a UN member; and immediate
report to the Security Council. Further, there are two types of self-defence
envisaged in this article: individual and collective self-defence.
(a)
Individual self-defence
Based
on state practice, individual self-defence is divided into four categories
namely, anticipatory self-defence, protection of nationals living abroad,
assertion of legal rights and armed reprisals.[8]
(i)
Anticipatory
self-defence
Anticipatory
self-defence refers to defence against imminent armed attacks.[9]
It is pre-emptive in nature, whereby a military strike is carried out before
the enemy’s actual attack. The party on the defensive strikes its opponent first,
in anticipation of an expected future attack. The exercise of this right has
been controversial. It is accepted on some occasions, yet rejected on others. When
Israel invoked this right in 1981 by bombing a nuclear reactor in Iraq,
claiming that the reactor was used to make bombs which would be used against it
and therefore, ‘entitled to destroy the reactor as an act of anticipatory
self-defence,’ it was condemned by the UN Security Council.[10]
But when the United States invoked the same right to justify its bombing of
Libya in 1986, in protest ‘against acts of state-sponsored terrorism,’ it
received approval from the UN Security Council.[11]
The
controversy surrounds the question is whether the phrase ‘if an armed attack
occurs’ permits anticipatory self-defence attacks. On the one hand, it is argued
that an armed attack has to occur
before regard to self-defence can be had,[12]
which effectively renders anticipatory self-defence illegal. On the other, it
is strongly argued that Article 51 does not in any way limit the circumstances
in which self-defence in general may be resorted to; and that the word ‘if’
does not mean ‘if and only if,’[13]
such that the article’s language is permissive of several circumstances,
including anticipatory self-defence. This ambiguity is a weakness in the law. A
clear prohibition of anticipatory self-defence will strengthen it by preventing
abuse. Considering that more often than not, the right of anticipatory
self-defence has been rejected by the Security Council,[14]
this will make the law more effective in guaranteeing international peace and
security, through enhanced restraint by states.
(ii)
Protection of nationals
abroad
Under
international law, there can be no state without people, because one of the
requirements for recognition of statehood is a permanent population.[15]
The entity seeking recognition as such should not be terra nullius i.e. without people. Therefore, it is the population
that in fact makes up a state and on this basis it is argued that the use of
force to protect nationals living abroad is justified as a form of self-defence.[16]
It is also said that the use of force in this situation is justified because naturally
it is a right which is exempt from the operation of Article 2(4) of the UN
Charter since its objective is not to compromise territorial integrity or political
independence of the attacked state.[17]
The
most prominent example of the exercise of this right was the 1976
Israeli rescue mission at Entebbe Airport, in Uganda, in which Israel used
armed force to rescue its nationals held hostage by President Idi Amin’s
government.[18] Then,
there is the Icelandic Fisheries Case between Iceland and Britain,[19]
resulting from the late 1950s and early 1960s dispute between the two countries,
where British vessels were used ‘to protect the asserted right of the British
trawlers to fish in the disputed zone’[20]
on account of protecting British nationals fishing in the disputed zone.
(iii)
Assertion of legal
rights
The
conduct of international relations inevitably results into legal rights,
accruing to states, which are enjoyable and exercisable over others. On account
of this, sometimes states resort to using force as a means of asserting accrued
rights.[21]
In such situations, the question has always been whether it is ‘lawful for a
state to use a degree of force in the assertion of its legal rights.’[22]
The answer is in the affirmative because in the
1946 Corfu Channel Case between Britain and Albania,[23]
a British warship was struck by Albanian mines when exercising its right of
innocent passage in travelling through the North Corfu Strait. Britain sent
additional warships to ‘sweep the minefield.’ The International Court of
Justice (ICJ) rejected Albania's claim that British display of force was a
violation of Albania's sovereignty, since neither Albania's territorial
integrity nor political independence was affected.
(iv)
Armed reprisals
Armed
reprisals are acts of retaliation. They are counter actions in the form of a
defensive nature,[24]
which are ‘punitive in character ... seek[ing] to improve reparation
for the harm done, or to compel a satisfactory settlement of the dispute
created by the initial illegal act, or to compel the delinquent state to abide
by the law in the future.’[25]
Hence, unarmed reprisals that don’t involve the use of force may
be lawful, but certainly not armed reprisals.[26]
It follows therefore, that self-defence excludes the right of armed reprisal.[27]
This is why the UN General Assembly, in 1970, declared that ‘States have a duty
to refrain from acts of reprisal involving the use of force.’[28]
The ICJ, in 1996, also advised that
armed reprisals are unlawful.[29]
This firm stance has curbed unnecessary state antagonism. Even the Security
Council has occasionally condemned Israel for its armed reprisals against its
Arab neighbours.[30]
(b)
Collective self-defence
The
right of collective self-defence needs better definition and clarity, as it is
not clear what is collective about
self-defence. Is it about a state’s collective exercise of
its individual rights of self-defence,[31]
or the exercise of a right by one or more states on behalf of the attacked state?’[32]
The North Atlantic Treaty of 1949
favours the latter definition, providing that, ‘... the
Parties, separately and jointly, by
means of continuous and effective self-help and mutual aid, will maintain and develop their individual
and collective capacity to resist armed attack.’[33]
Thus, NATO members understand collective self-defence as each
party undertaking to defend every other party against attack.’[34]
The ICJ
has adopted the same line. In the 1986 Nicaragua Case, it said that one
state can only defend another only if that other state is the victim of an
armed attack and asks the first state to defend it.[35]
This majority stand guarantees international peace and security because through
collective efforts, states are better placed to ward off international bullies
and curtail war mongering.
2.
UN
Authorisation
This
second exception is deciphered from the general scheme of the UN Charter,
particularly Chapter VII thereof,
concerning action with respect to threats to the peace, breaches of the peace,
and acts of aggression and from the purposes and principles of the United
Nations especially, as indicated in Article 1(1) on maintaining
international peace and security. It is given by the UN Security Council under
chapter VII of the UN Charter, after ‘... determin[ing] the existence of any
threat to the peace, breach of the peace, or act of aggression ...’ in
accordance with Article 39 thereof. If the Council is convinced that any of
these circumstances exist, it may, by resolution, invoke remedial measures such
as economic, diplomatic and military or a combination of sanctions.[36]
This authority is usually for purposes of collective security and UN
enforcement.[37] A
good example here is the case of the Gulf War where the US
and its allies justified their use of force against Iraq, following its
invasion of Kuwait. In order to restore international peace and security in the
area, the Security Council adopted Resolution 678 of 1990 authorizing UN members, co-operating with
the Government of Kuwait, to remove Iraq from Kuwait.[38]
This option guarantees international peace and security because it enhances the
effectiveness of the UN in fulfilling its mandate. The UN may not be a paper
tiger.
B.
United Nations General
Assembly Resolutions and Declarations
The
United Nations General Assembly is the de facto legislative body of the United
Nations,[39]
whose resolutions and declarations however, are not binding on member states,
but as the US Secretary of State suggested, only recommendatory.[40]
Nevertheless, the Assembly’s resolutions have great evidentiary value’ and have
been accorded considerable weight by international justice tribunals.[41]
One of the resolutions adopted by the UN General Assembly is Resolution 3314 (XXIX) of 1974 on
definition of aggression.[42]
The Assembly was ‘Deeply, convinced that the adoption of the
Definition of Aggression would contribute to the strengthening of international
peace and security’ and ‘Considering also that, since aggression is the most
serious and dangerous form of the illegal use of force ...,’ prohibited aggression
under Article 5 of the Annex to the resolution. It is stipulated under clause
(1) of article 5 that no political, economic, military or other considerations
may serve as justifications for aggression. Clause (2) declares aggression as a
crime against international peace, giving rise to international responsibility.
Finally, under clause (3), any territorial acquisition or special advantage
resulting from aggression is unlawful. Article 1 of the Annex to Resolution 3314 (XXIX)
defines aggression. It states that, ‘Aggression is the use of armed
force by a State against the sovereignty, territorial integrity or political
independence of another State, or in any other manner inconsistent with the
Charter of the United Nations ....’ Therefore, Russia’s occupation and annexation
of Ukraine’s Crimea territory in March, 2014, is an act of aggression.
Fortunately, the UN has rejected Russia’s actions.[43]
This firm stand will eventually guarantee international peace and security.
C.
International Customary
Law
International
customary law emerges from the practice of states,[44]
and concretizes into binding norms, having the force of law. Based on the broad
concept of self-defence, states in this respect justified their use of force on
grounds of intervention and self-determination.[45]
1.
Armed
Intervention
Armed intervention in the affairs of other states is generally
prohibited, under Article 1 of Resolution
2131 (XX), which states that ‘No State has the right to
intervene, directly or indirectly, for any reason whatever, in the internal or
external affairs of any other State.’[46] The
article further condemns any ‘... armed intervention and all other forms of
interference or attempted threats against the personality of the State or
against its political, economic and cultural elements ....’ The ICJ restated this principle in the Nicaragua case saying that the principle of non-intervention
involves the right of every sovereign state to conduct its affairs without
outside interference.[47] It follows therefore, that
it ‘is a
universally recognized and acknowledged obligation of all States not to
encroach on another State's territory or affairs.’[48] There are two common, but controversial situations, however, in
which a state may intervene in the affairs of another state: humanitarian
intervention and intervention by invitation.
(a)
Humanitarian
intervention
Many
times, states have justified the use of force against others on humanitarian
grounds. For example, in 2011, America and its allies attacked and bombarded
Libyan military installations on this basis, to deter President Muammar Gadaffi
from killing protestors who were urging for his downfall. It is said that
humanitarian intervention is necessary for the ‘... protection of individuals
and groups of individuals against their own state.’[49]
That it helps ‘... prevent and suppress large-scale violations of human
rights.’[50] To
this end, the law is strong and effective enough to guarantee international
peace and security. But it is also said ‘... that intervention
on humanitarian grounds is "non-permissive", as it appears to violate
Article 2(4) [of the UN Charter] ....’[51]
It also appears illegal, in light of the unambiguous wording of Resolution 2131 (XX).[52]
This is an ambiguity in the law and to this extent, a weakness that renders it
ineffective. In order to cure it, the General Assembly should clear expressly
exclude humanitarian intervention from the prohibition in Resolution 2131 (XX).
(b)
Intervention by
invitation
It
seems settled that the ‘... use of force in intervention by invitation is legal.’[53]
That is why, for instance, the UN Security Council adopted Resolution
678 of 1990 authorizing UN
members, co-operating with the Government of Kuwait, to remove Iraq from
Kuwait.[54]
But there must be caution before intervening on invitation, because first, in
cases of national liberation movements, intervention by foreign states can only
be lawful if it is shown that the ‘... national liberation movement (or the
people whom it claims to represent) was the victim of an armed attack’[55]
and second, where there is a legitimate government, it ‘... may invite the
forces of another state on to its territory for any purpose lawful under
international law, that is, not for genocide, wars of aggression, or to prevent
an exercise of self-determination, etc.’[56]
This opening is important for guaranteeing international peace and security as
evidenced by Uganda’s deployment of troops in South Sudan, in December 2013, on the (controversial) invitation of the
South Sudanese government to prevent the possibility of genocide.
2.
Self-Determination
This is ‘the
right of a people living in a territory to determine the political and legal
status of that territory.’[57]
It is supported by developing states which justify the use force to achieve
self-determination, claiming also that other states have a right to assist them
with force to achieve this objective.[58]
A lot of controversy surrounds this alleged right, so much because the UN
Charter is generally silent about it. The most the UN has said about it is in
the Annex to Resolution 2625 (XXV) of
1970 i.e. Declaration on Principles of International Law Concerning Friendly
Relations and Co-operation among States in Accordance with the Charter of the
United Nations, Principle 1
of which imposes a duty on every state ‘... to
refrain from any forcible action which deprives peoples referred to above in
the elaboration of the present principle of their right to self-determination
and freedom and independence.’[59]
It is therefore illegal for a state to ‘frustrate
self-determination’ of the people of another.[60]
This is an effective deterrence to imperialist states that may want to take
over the territories of others in pursuit of their domineering interests and it
guarantees international peace and security.
3.
Conclusion
The
law on use of force is fairly strong enough to guarantee international peace
and security in the 21st century. 14 years into the century, the
world is generally more peaceful, secure and stable now than before. The
possibility of wars the magnitude of the two great world wars of the twentieth
century, the Cold War or the frequent interstate clashes of the 19th
century, is least imaginable today. Intrastate state conflicts like the ongoing
crisis in Syria are the biggest threats to world peace and security now, because
an otherwise internal conflict has the capacity to destabilize an entire region.
However,
there are challenges like the unilateral American invasion of Iraq in 2001, in
spite of objection by the United Nations and now the 2014 Russian annexation of
Crimea. In light of these pockets of disorder, some scholars have doubted and
questioned the effectiveness of the implementing mechanisms of the law on use
of force, in guaranteeing international peace and security. It is believed
that, ‘Reliance on the United Nations Security Council alone to combat
terrorism, halt the proliferation of nuclear weapons, or intervene to prevent
genocide and “ethnic cleansing” would be obvious folly.’[61]
Further, that, ‘The Council has proven to be all but hapless in confronting such
challenges, and, despite persistent, but unavailing, calls for reform, will
remain so,’[62]
and that ‘The lesson of experience is that “when ... the Great Powers and
relevant local powers are in agreement ... the elaborate charades of the
Security Council ... are unnecessary. When those powers do not agree, the U.N.
is impotent.”’[63]
These fears may be well founded, but it is submitted that there is no cause for
alarm since the challenges on which they are based are the exception, not the
norm, in today’s international relations. They will be ironed out gradually as
people continue to interact more meaningfully across national borders through
avenues like international trade, civil society networks and other
socio-political engagements.
Nevertheless,
it is critical that international law enforcement mechanisms be strengthened. For
instance, we need standby United Nations personnel – army, police and
humanitarian, under the absolute command and deployment of the Secretary
General, to respond rapidly to emergencies. The UN is expected to respond
quickly to crises, yet presently it delays to respond, simply because it is a
beggar (and beggars have no choice) that is only dependent on the goodwill of
states. More often than not, states drag their feet, haggling over petty
matters like who to deploy, how many
personnel and who to pay, how much,
while the carnage on ground escalates. This is what happened during the 1994
Rwanda genocide where about 800,000 people died in just 100 days. The UN, in
exercise of its mandate, should never allow it to happen again.[64]
Notes and References
[1] Zhores Medvedev,
‘Stalin and the Atomic Bomb’ in Roy Medvedev and Zhores Medvedev, The Unknown Stalin: His Life, Death, and
Legacy, translated by Ellen Dahrendorf (2003), at 139.
[2] William H. McNeill, The Pursuit of Power (1982), at 307, ‘Men
went gladly to war in August 1914 in the more urbanized parts of Europe. Almost
everyone assumed that fighting would last only a few weeks. In anticipation of
decisive battles, martial enthusiasm bordering on madness surged through German,
French and British public consciousness.’
[3] Ibid., at 314.
[4] Ibid., at 358-359.
[5] Preamble to the Charter
of the United Nations.
[6] Martin A. Dixon and
Robert McCorquodale, Cases and Materials
on International Law (2000), at 561.
[7] Anthony D’Amato (ed),
International Law Anthology (1994),
at 115.
[8] Ms
Ong Yen Nee, ‘When States May Lawfully Resort to Armed Force’ 28 JSAF (2002) 3, at paragraph 4. Available
at http://www.mindef.gov.sg/safti/pointer/back/journals/2002/Vol28_3/8.htm.
[9] Ibid., at paragraph 12.
[10] Peter Malanczuk, Akehurst's
Modern Introduction to International Law (1997), at 313.
[11] Ibid.
[12] Ibid., at 311.
[13] Ibid., at 311-312.
[14] Ms Ong Yen Nee, supra note 8, at paragraph 13.
[15] Peter Malanczuk, supra note 10, at 75.
[16] Ms Ong Yen Nee, supra note 8, at paragraph 14.
[17] Ibid.
[18] Jeffrey A. Sheehan, ‘THE ENTEBBE RAID:
The Principle of Self-Help in International Law as Justification for State Use
of Armed Force, TFF (1977), at 140, disputes this, ‘...
contend[ing] that this label is not applicable and that its use is too
inconsistent and too vague to provide a convincing legal justification for the
raid.’
[19] International Court
of Justice, Fisheries Jurisdiction (United
Kingdom of Great Britain and Northern Ireland v. Iceland), ICJ Reports (1974), at 3.
[20] Katz, 'Issues Arising
in the Icelandic Fisheries Case', 22 ICLQ (1973), at 88.
[21] Ms Ong Yen Nee, supra note 8, at paragraph 17.
[22] Katz, supra note 22, at 87.
[23] International Court
of Justice, Corfu Channel (United Kingdom
of Great Britain and Northern Ireland v.
Albania), ICJ Reports (1949), at 4.
[24] Ms Ong Yen Nee, supra note 8, at paragraph 18.
[25] D. Bowett, 'Reprisals
Involving Recourse to Armed Force', 66 AJIL (1972) 1.
[26] Malcolm N. Shaw, International Law (1997), at 786.
[27] Peter Malanczuk, supra note 10, at 316.
[28] Ibid.
[29] International Court
of Justice, Legality of the Threat or Use
of Nuclear Weapons, ICJ Reports (1996), at 226.
[30] Ms Ong Yen Nee, supra
note 8, at paragraph 18.
[31] Ibid., at paragraph 19.
[32] Martin A. Dixon and
Robert McCorquodale, supra note 6, at
575.
[33] Article 3 thereof (emphasis
added).
[34] Peter Malanczuk, supra note 10, at 318.
[35] International Court
of Justice, Case Concerning the Military
and Paramilitary Activities in and Against Nicaragua (Nicaragua V. United States of America) (Merits),
ICJ Reports (1986), at 14. For
avoidance of doubt, the Court stressed that this can only be lawful, as an
exception, only when the response was provoked by an armed attack.
[36] Ms Ong Yen Nee, supra note 8, at paragraph 34.
[37] Ibid.
[38] S/RES/0678 (1990), 29
November 1990.
[39] S.K. Verma, An Introduction to Public International Law
(1998), at 45.
[40] See, Anthony D’Amato
(ed), supra note 7, at 105.
[41] S.K. Verma, supra note 39.
[42] GA Res. 3314 (XXIX), 14 December 1974.
[43] MSN News,
‘UN rejects Russian annexation of Crimea’ (2014). Available at http://news.msn.com/world/un-rejects-russian-annexation-of-crimea,
accessed on 12-04-2014, at 15:33 hrs.
[44] Henkin et al., International Law: Cases & Materials (1993), at 54.
[45] Ms Ong Yen Nee, supra note 8, at paragraph 38.
[46] GA Res. 2131 (XX), 21 December 1965.
[47] International Court of Justice, Case Concerning the Military and Paramilitary Activities in and
Against Nicaragua (Nicaragua V.
United States of America) (Merits), supra
note 35, at paragraphs 202-209.
[48] Jeffrey A. Sheehan , supra note 18, at 3.
[49] R. Lillich, 'Forcible Self-Help
by States to Protect Human Rights' 53 ILR
(1967-1968), at 325.
[50] Martin A. Dixon and Robert McCorquodale, supra note 6, at 579.
[51] Ms Ong Yen Nee, supra
note 8, at paragraph 27.
[52] GA Res. 2131 (XX), 21 December
1965.
[53] Ms Ong Yen Nee, supra
note 8, at paragraph 28.
[54] S/RES/0678 (1990), 29
November 1990.
[55] Peter Malanczuk, supra note 10, at 338.
[56] Ibid., at 581.
[57] Ibid., at 326.
[58] Martin A. Dixon and Robert McCorquodale, supra note 6, at 585.
[59] GA Res. 2625 (XXV), 24
October 1970.
[60] Peter Malanczuk, supra note 10, at 337. Since there is nothing that
endorses the use of force to achieve self-determination, it is believed that,
‘In view that Article 2(4) propounds states to conduct their international
relations through peaceful means, the use of force to achieve
self-determination is likely to be unlawful’ (See, Ms Ong Yen Nee, supra note 8,
at paragraph 29), it is
nevertheless submitted that this is erroneous, because the struggle for
self-determination is not one in the course of international relations, which is the concern of Article 2(4) of
the UN Charter, as it is a purely domestic matter that the UN has tactfully
left to states to handle internally. What is not prohibited is legal. People
living in a given state are not prohibited to use force in determining its
legal and political status. Therefore, it is lawful for them to use of force in
doing so.
[61] Robert J. Delahunty
& John Yoo, ‘The “Bush Doctrine”: Can Preventive War Be Justified?’ 32 HJLPP (2009), at 845.
[62] Michael W. Doyle, Striking First: Pre-emption and Prevention
in International Conflict (2008), at 20-23; John C. Yoo & Will
Trachman, ‘Less than Bargained for: The Use of Force and the Declining
Relevance of the United Nations’ 5 CJIL
(2005), at 379.
[63] Robert J. Delahunty
& John Yoo, supra note 61.
[64] Under Article 1(1) of
the Charter of the United Nations.
Consider, for instance, that recently, on Thursday, 10 April, 2014, the UN
Security Council voted to deploy troops to Central African Republic in order to
curb the on-going deadly religious conflict there, but the troops will arrive
in September this year – five months after – precisely for the above reasons!
Imagine how many more people will have died before the UN responds in
fulfilment of its mandate to maintain international peace and security.
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